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RITE 1 DIGITAL. – PRIVACY POLICY


Effective Date: This Privacy Policy was last revised on January 2, 2021.

Welcome! You have arrived at a website that is provided by Rite 1 Digital, Inc. (“IN”or “we,” “our” or “us”). Our network of sites consists of United Digital Music Group and Ingrooves Rights Services. This “Privacy Policy” governs your use of our websites (including, without limitation, both mobile and online versions of our web sites), and also applies to your use of all features, applications, content, downloads and other services that we make available through these websites and/or that post a link to this Privacy Policy (collectively, referred to herein as the “Site”), regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Site (unless otherwise stated below).

 

To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

 

In addition, please review the Site’s Terms of Use which governs your use of the Site. By using our Site, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below, unless such consent is prohibited by applicable law.

 

1. WHAT INFORMATION DOES THE SITE COLLECT?

Personal Information and Demographic Information. On the Site, we may ask you to provide certain categories of information such as: (a) personally identifiable information, which is information that identifies you personally, such as your first and last name, email address and phone number (“Personal Information”); and (b) demographic information, such as information about your gender (“Demographic Information”). We collect Personal Information and Demographic Information from you on the Site in the following places (among others):

 

(i) Registration. Our Site may give you the opportunity to register with us, and sometimes registration is required before certain site features can be used. Our registration forms on our Site may request your contact information (such as your name, email address, mailing address, etc.), demographic information (such as your country, gender, etc.), and profile data (such as your music preferences, entertainment practices, etc.). You may be assigned a Site username or password. For our internal purposes, we use this information to communicate with you and provide the services you have requested and to provide a more personalized experience on our Site. For example, your registration may allow you to use and post to Site message boards, create site profiles, etc. We use aggregate demographic and profile information about our audience in order to improve our service, for research purposes, marketing/promotional purposes or for industry reporting purposes, among others.

 

(iii) Communications with Us. We have features where you can submit information to us (such as when contacting us with a question or feedback). We may retain your emails and other information you submit to us for our internal purposes, and to help us to serve you better.

 

(v) Interactive and Community Features. Our Site may offer interactive and community features, such as message boards, chat, email accounts, short message service (SMS), instant messaging, profiles, personal homepages, etc. All information posted or sent through these features may be publicly available, and you should be aware that when you voluntarily disclose personal information (e.g., user name, email address, phone number) through these features, that information can be collected and used by others and may result in unsolicited communications from other people. Users’ posts may be publicly and/or internally associated with their profiles/screen-names. Users are solely responsible for the content of messages they post or send on public forums.

 

(vi) Contests, Sweepstakes and Surveys. We may also have contests, sweepstakes and surveys at our Site. When you enter or participate in them, we request contact information from you (such as your full name, email address, mailing address, and telephone number) and may also request demographic or profile information. We will use the information you provide for the purpose of conducting the promotion (for example, to contact you if you have won). We may also use the information to send you newsletters and other information we think may be of interest. Recipients of our mailings can unsubscribe by following instructions that may appear at the end of the email communication. Any personal information we collect may be associated with registration information. We may share aggregate information with others. We may sometimes partner with sponsors in offering contests, sweepstakes or surveys, and may share (provide and receive) information with them. By entering or participating in such contests, sweepstakes, and surveys, you affirmatively consent to our collection and use of your data, unless such consent is prohibited by applicable law.

We do not generally rely on obtaining your consent to process your personal data. Where we process personal data based on consent, we will ask for your consent on a case-by-case basis. If we obtain your consent for any use of your personal data, you have the right to withdraw your consent at any time.

 

2. AUTOMATIC DATA COLLECTION

In addition to any Personal Information or other information that you choose to submit to us via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a “Device”) whenever you visit or interact with our Site. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information. This Usage Information may include:

  • your IP address or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to our Site;
  • the areas within our Site that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and certain other Device data, including the time of day, among other information.

We may use various developed methods and technologies to collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

 

Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com.

Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.

 

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

 

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

 

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

 

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

 

We may use Tracking Technologies for a variety of purposes, including:

 

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Site functionality.

 

Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site. 

 

Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site. 

 

Targeting-Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Site and third-party sites based on how you interact with our content and ads. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you. Further information on this, and your opt-out choices is found in Section 5 below. 

There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. This Privacy Policy does not apply to these third-party Tracking Technologies. Please refer to the privacy notices of these third parties to understand their privacy practices.

 

3. CALIFORNIA DO NOT TRACK DISCLOSURES

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

 

4. INFORMATION THIRD PARTIES PROVIDE ABOUT YOU

We may receive information about you from our affiliates and others that use the Site, such as when they submit content to us or post on the Site. Additionally, we may, from time to time, supplement the information we collect directly from you on our Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to determine your location, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information unless we have disclosed otherwise. In no other circumstances do our promises under this Privacy Policy apply to information we receive about you from third parties.

 

5. INTERACTIONS WITH THIRD PARTY SITES

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you wish to post a comment on one of our blogs, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration process on the Site, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Site, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. 

 

INI may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.

 

6. HOW DO WE USE THE INFORMATION COLLECTED?

We may use your Personal Information, Demographic Information or Usage Information for various purposes, including:

  • to process transactions or provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming events;
  • to enable you to participate in a variety of the Site’s features such as to enable you to participate in online entry sweepstakes, contests or other promotions;
  • to improve the Site, marketing endeavors or our Site offerings
  • to customize your experience on the Site or to serve you specific content or ads that are relevant to you;
  • to provide customer support;
  • to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies;
  • to notify you of product recalls or providing other information concerning products you have purchased;
  • to identify your product and Site preferences so that you can be informed of new or additional products, services and promotions;
  • to improve merchandise selections and the overall shopping experience at the Site;
  • for internal business purposes; and
  • for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

We keep your Personal Information for as long as it is required by us for the purposes set forth in this Privacy Policy. We will generally delete your Personal Information from our systems when it is no longer necessary for these purposes.

 

7. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information that we have collected directly from you on our Site with third parties for those third parties’ direct marketing purposes unless you have consented at the time you provide your Personal Information or as otherwise disclosed in this Privacy Policy. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. INI may disclose your information as follows:

 

(i) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Site or link to them from our Site. This may include using third party tools such as Facebook, Twitter, Pinterest or other third party posting or content sharing tools. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

 

(ii) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as: 

1. to assist us in Site operations;

2. to manage a database of customer information;

3. hosting the Site;

4. designing and/or operating the Site’s features;

5. tracking the Site’s activities and analytics;

6. enabling us to send you special offers or perform other administrative services; and

7. other services designed to assist us in maximizing our business potential.
We may provide vendors with access to your information to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own technologies on your Device and they may otherwise collect or have access to information about you. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

 

(iii) Administrative and Legal Reasons.

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties:

  1. to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law;
  2. to protect and/or defend the Site’s Terms of Use or other policies applicable to the Site, including investigation of potential violations thereof;
  3. to protect the safety, rights, property or security of the Site or any third party; and/or
  4. to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you as allowed by applicable law.

 

(iv) Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information:

  1. to a subsequent owner, co-owner or operator of the Site or applicable database; or
  2. in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your information to be shared or transferred to third parties without your permission.

 

(v) Artist’s Sites. Information provided at Artist sites that we host or manage may be shared with that Artist, including their management, representatives, and any new label they may join. As with other third parties, we are not responsible for how the Artists handle the data once they receive it. When we have co-branded or sponsored services, when we host a site, or when we join with other parties to provide specific services, we may share (provide and receive) your personal information with them. By visiting these sites, you affirmatively consent to our collection, use and distribution of your data, unless prohibited by applicable law.

 

8. WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?

 

(i) User-Generated Content and Public Information. The Site may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on profiles, blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties.Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that INI does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Our promises under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Site. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Site.

 

(ii) Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Site, please review our Terms of Use.

 

9. ADS AND INFORMATION ABOUT YOU

We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“Behavioral Ads”). 

Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below. Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own technologies on your Device and track certain behavioral Usage Information via a Device Identifier. These third party technologies may be set to, among other things:

1. help deliver advertisements to you that you might be interested in;

2. prevent you from seeing the same advertisements; and

3. understand the usefulness of the advertisements that have been delivered to you.

Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.
Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. Further, while sites use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver Behavioral Ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/#completed. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.

 

10. CHOICE By accepting this Privacy Policy, you expressly choose to receive certain communications from us and third parties, and you expressly agree to the privacy practices described herein, unless applicable law provides otherwise. Our Site may also provide you with additional specific opportunities to select communications you wish to receive. You may change your privacy preferences (e.g., choose to cease receiving certain communications), by informing us of your new preferences. We will be able to honor your new preferences most quickly if you inform us of them by following the appropriate instructions in any communication you receive from us.

Please be aware that messages you receive from us through SMS and instant messaging systems (and other systems apart from email) may not include an option to cease receiving communications; to change your privacy preferences with respect to those communications, please go to the profile page at the Site where you provided your personal information or direct your instructions to the Contact identified at the end of this Privacy Policy.

 

11. RIGHTS If you are located in the European Economic Area (“EEA“), you may have certain rights, including: • the right to direct us not to disclose nonpublic personal information to a nonaffiliated third party;

  • the right to access your personal data;
  • the right to restrict the use of your personal data;
  • the right to have incomplete or inaccurate data corrected;
  • the right to ask us to stop processing your personal data;
  • the right to request for us to “port” your personal data in a portable, reusable format to other organizations, where applicable and possible; and
  • the right to require us to delete your personal data in some limited circumstances. 

Some of the Personal Information we collect Is necessary for us to perform any contracts we have for you, so if you do not wish to provide that data, it may affect our ability to provide our services to you. In addition, in some cases, we may encounter circumstances where applicable laws or other mandatory requirements require us to retain or disclose your Personal Information.

If you would like to exercise any of these rights or have questions about them, please send us a written statement to the contact information set forth below.

 

12. DATA COLLECTION FROM CHILDREN Each Site is a general audience web site and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us at contact@udmgrp.com.

 

13. TRANSFERS OF INFORMATION ACROSS BORDERS

Each Site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy, unless such consent is prohibited by applicable law.

When we transfer data from within the EEA to recipients located outside of the EEA, we will ensure that the recipients will have in place data transfer agreements and safeguards using terms approved by the European Commission.

Please contact us if you have questions about any international transfers.

14. SECURITY We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

 

15. MERCHANT/E-COMMERCE AREAS

Some of our sites have merchant/e-commerce areas, where users can purchase music and merchandise. Those areas are powered by a third-party e-commerce vendor that we have engaged. Personal Information (excluding credit card or other financial information) collected by the vendor is shared with INI and is subject to this Privacy Policy.

 

16. LINKS We may provide links to non-Rite 1 Digital, Inc. sites. We are not responsible for those other sites, their privacy policies or how they treat information about their users, and we advise you to check their privacy policies.

 

17. PRIVACY POLICY CHANGES We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. However, we will not use your Personal Information in a manner materially different than promised at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

 

18. CONTACT If you have any questions about our privacy practices, please feel free to contact us at: 

Email at: contact@udmgrp.com

 

PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the applicable third parties regarding their privacy and data security policies and practices.